No Slowing Down: The EU Targets Russian Interests In 19th Sanctions Package

The newest sanctions package comes in the direct aftermath of both the United Kingdom and the United States having imposed significant sanctions earlier in October. From an EU perspective, a further 69 individual listings have been made, and restrictions have also been introduced within especially the energy sector, military industries, banking and crypto.

In this article, we highlight some of the key additions to the latest EU sanctions and how they may affect Danish businesses across sectors and industries:

Energy sector

• A ban on imports of Russian liquefied natural gas (LNG) into the EU will take effect in two stages: Long-term contracts will end by January 2027 and short-term contracts within six months. Existing transaction bans against two major Russian state-owned oil producers (Rosneft and Gazpromneft) have been tightened.
• Third-country actors have yet again been specifically targeted due to suspicion of circumvention of existing sanctions, including entities in China (two refineries and an oil trader). This is in line with the EU's approach in earlier sanctions packages.

Russia' shadow fleet

• 117 additional vessels have been added to the port access ban and ban on the provision of a broad range of services related to maritime transport. Reinsurance of such vessels forming part of the shadow fleet has likewise been prohibited. Now comprising more than 550 vessels and actors, the listings include banks in Kazakhstan and Belarus.

Financial sanctions

• Widespread sanctions include measures targeting crypto such as the stablecoin A7A5 and sanctions against the developer hereof in Kirgizstan as well as a platform on which the currency is being traded.
• As of 25 January 2026, EU actors may not engage with the Russian National Payment Card System ('Mir') or the Fast Payments System ('SBP'), significantly reducing any potential financial efforts with relation to the Russian market.
• Additional banks and oil traders are now targeted by transaction bans, including in so-called third countries such as Tajikistan, Kyrgyzstan, Hong Kong and the United Arab Emirates/UAE. Five Russian banks have similarly been added to the ban, effectively ruling out the possibility of Danish businesses facilitating payments directly or indirectly through such banks.

Military industries and trade

• New sanctions have been introduced against businesspersons and entities forming part of the Russian military-industrial complex, including operators from the United Arab Emirates/UAE and China suspected of producing and supplying dual-use goods in contradiction of the purpose of EU sanctions.
• Trade-related measures also include the listing of 45 new entities suspected of directly supporting Russia's military and industrial complex (circumvention) of export restrictions on computer numerical control (CNC) machine tools, microelectronics, unmanned aerial vehicles (UAVs) and other advanced technology items.

'Special economic, innovation or preferential zones'

• In an interesting turn of events, certain geographical areas of Russia's "special economic, innovation or preferential zones" have now effectively been made subject to an embargo, prohibiting inter alia any new or extended participation in ownership or control of entities located in such zone, or the maintenance of existing ownership or control of entities located in such zone after 25 January 2026. See the new Article 5ah for more details as well as the Belarus Regulation for Belarus-specific aspects.

Services

• Additional services have been added to the service prohibition; commercial space-based services, artificial intelligence services, and high-performance computing services.
• Further, a prior authorisation is now required for the provision, directly or indirectly, of any services to the Government of Russia (i.e., not limited to the specific services mentioned in the relevant Article).
• On an editorial note, Article 5n of Regulation 833/2014 (the Russia Sanctions) regarding the prohibition on services has been restructured and simplified. However, it should be noted that this entails certain changes in prior paragraph referrals.

Ownership and control

• New definitions on "owning" and "controlling" have been added to Regulation 269/2014 in relation to asset freeze of specific persons or entities. The definitions are in line with the previous guidance from the EU Council in its "Best Practices for the effective implementation of restrictive measures". Specifically, ownership is established upon being in possession of 50% or more of the proprietary rights of a legal person, entity or body, or having a majority interest therein, whereas control is a concrete assessment which can be based on several factors, with a non-exhaustive list of examples being included in the definition.

What's next?

According to Kaja Kallas, High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council, the 19th sanctions package "will not be the last" (read the press release). Based on developments since 2014 and especially in the aftermath of February 2022, EU businesses are well-advised to ensure a continued focus on geopolitical tendencies and internal housekeeping to react proactively once new developments occur.

A natural starting point for EU operators is to frequent the EU Sanctions Map containing an overview of the EU's sanctions on a global scale.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.